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International

  • October 19, 2018

    OECD Advises On Tax Base Erosion In Mineral-Rich Countries

    The Organization for Economic Cooperation and Development issued reports Friday addressing how mineral-rich developing countries can boost tax revenues by fighting erosion of their tax bases through corporate profit shifting and improving the capacity of national tax authorities.

  • October 19, 2018

    Deceased La. Man Hid $11.7M Income Overseas, Tax Board Says

    The Louisiana Board of Tax Appeals has upheld in a decision released Friday more than $850,000 in tax assessments against the succession of a deceased individual, determining he fraudulently stashed more than $11.7 million in income overseas to evade taxes during a six-year span.

  • October 19, 2018

    Taxation With Representation: Wachtell, Simpson, Cravath

    In this week’s Taxation With Representation, Harris Corp. snags L3 Technologies Inc. for $35 billion, Novartis AG inks $2.1 billion deal with Endocyte Inc., Invesco Ltd. scoops Massachusetts Mutual Life Insurance Co.’s asset management unit OppenheimerFunds for $5.7 billion, and Oncor Electric Delivery Co. and Sempra Energy nab InraREIT for $1.3 billion.

  • October 19, 2018

    Dutch Question Commission Figures, Logic In Ikea Tax Case

    The European Commission got its figures wrong in analyzing Inter Ikea’s tax treatment, Dutch Finance Minister Menno Snel said in a letter defending his administration against accusations of breaching European Union rules against unfair competition.

  • October 19, 2018

    British Columbia Proposes Speculation Tax On Vacant Homes

    The government of British Columbia has introduced legislation that would impose a speculation tax on vacant homes in the Canadian province.

  • October 19, 2018

    Biz Gets Extra Time To Elect As International Sales Corp.

    The Internal Revenue Service released a private letter ruling Friday granting a domestic corporation extra time to elect as an interest charge domestic international sales corporation.

  • October 19, 2018

    Too Early To Tell If EU Rules Curb Tax Evasion, Report Says

    A recent European Parliament report said that while the European Union has taken steps in recent years to fight tax evasion and avoidance, it’s too early to tell if they’re working.  

  • October 19, 2018

    Transfer Pricing And An 'Ironic' Letter To IRS: SALT In Review

    From how transfer pricing is affecting state corporate income taxes to blue states' "ironic" letter asking the new IRS commissioner to repeal proposed state and local tax deduction cap regulations, Quarles & Brady LLP's David Brunori shares his thoughts on this week's important state and local tax matters.

  • October 19, 2018

    Pension Transfer Liable For Tax After Death, Court Rules

    A terminally ill woman who transferred retirement savings into a personal pension plan six weeks before her death is still liable for inheritance tax on the money, under a landmark ruling from the Court of Appeal in London.

  • October 18, 2018

    EU Drops Case Against Ireland Over Apple Tax Bill

    Europe’s competition enforcer said Thursday that it had formally dropped its case seeking to force Ireland to recover €13 billion ($14.9 billion) in alleged illegal state aid from Apple Inc., after the company gave the Irish government the back taxes plus interest to hold while they both appeal the underlying state aid decision.

  • October 18, 2018

    Africa Must Address Tax Capacity, Revenue Collection: Report

    African nations with below-average tax revenues must address their tax capacities — how much they can impose on individuals and businesses — and their collection abilities, according to a report published by the Brookings Institution on Wednesday.

  • October 18, 2018

    New Law Could Stop $63B Share Tax Scam, EU Says

    A $63 billion European scandal involving multiple claims for dividend tax refunds exploits a failure of national cooperation, but new European Union laws could plug the gap, the European Commission said Thursday.

  • October 18, 2018

    Papua New Guinea Agrees To Tax Inspectors Partnership

    Papua New Guinea will participate in a Tax Inspectors Without Borders project to tackle tax base erosion and profit shifting by multinational businesses in the country, the Organization for Economic Cooperation and Development said Thursday.

  • October 18, 2018

    VAT Apportionment Must Count Initial Value, EU Court Rules

    The European Court of Justice, ruling Thursday on the ability of a U.K. division of Volkswagen to deduct so-called residual value-added tax, said that in determining VAT deduction, countries must consider the initial value of goods when they are supplied, as this ensures better apportionment than basing it on turnover.  

  • October 18, 2018

    IRS Updates Web-Based FATCA File Transfer Service

    The Internal Revenue Service on Thursday said it updated an online file transfer service the agency uses to obtain information from foreign governments on American taxpayers, pursuant to the Foreign Account Tax Compliance Act.

  • October 18, 2018

    Free Ports Should Share Data With Tax Officials, Analyst Says

    Lawmakers should enable customs authorities and free ports — warehouses in tax- and duty-free zones — to share information more directly with tax authorities, a European Parliament analyst suggested Thursday.

  • October 18, 2018

    Oil Cos.' Tax Bill Reports Need To Improve, Activists Say

    Oil, gas and mining companies are still managing to hide details of the taxes and fees they pay to governments thanks to loopholes and implementation failures in a European Union transparency law, a campaigning group said Thursday.

  • October 17, 2018

    Caplin & Drysdale Picks Transfer Pricing Pro As New President

    A transfer pricing expert and member of Caplin & Drysdale Chtd.’s international tax and tax controversy groups has been promoted to president, the firm recently announced.

  • October 17, 2018

    IRS Demands Fines For Calif. Family's Unreported Bank Funds

    The Internal Revenue Service hit back at a California family’s lawsuit seeking relief from penalties for not reporting offshore bank accounts, with counterclaims of its own Wednesday to enforce nearly $400,000 in penalties.

  • October 17, 2018

    Ireland Updates Guidelines For Startup Tax Benefits

    Startups and other small firms can apply for favorable tax rates under Ireland’s new patent box regime, even if the technology has not been patented, according to guidelines recently issued from the Ireland Revenue Commissioners.

Featured Stories

  • VAT Refund Delays In Africa Cause Rancor Among Companies

    Alex M. Parker

    Mining and other extractive companies are waiting months, sometimes years for value-added tax refunds on exported materials in Africa, creating tension with local tax authorities and belying the VAT’s promise of administrative ease for cash-strapped developing countries.

  • Switzerland Looks Ahead To A Topsy-Turvy Tax Referendum

    No Photo Available

    Swiss voters could soon once again nix a reform aiming to close tax avoidance loopholes, amid concerns that compensating tax cuts and research incentives contained in draft legislation tip the balance too far in favor of business interests.

  • Midsize Companies Face Disproportionate Anti-Avoidance Costs

    No Photo Available

    The Organization for Economic Cooperation and Development’s efforts to combat international tax avoidance are causing middle-market companies to get caught up in some of the same nets as large multinationals, but with fewer resources to untangle themselves.

Expert Analysis

  • Are You An Inadvertent US Shareholder In A Foreign Corp?

    Saren Goldner

    Attorneys at Eversheds Sutherland LLP provide a practical approach to evaluating ownership of non-U.S. entities under the new Subpart F rules and to dealing with the consequences of becoming a U.S. shareholder in a CFC in which you have no control.

  • Foreign Investors May Benefit From Opportunity Zones

    Galia Antebi

    Galia Antebi and Nina Krauthamer of Ruchelman PLLC discuss the elements of the opportunity zone tax code provision and the related options for non-U.S. investors, who generally are not subject to U.S. taxation on dispositions of capital property other than U.S. real property.

  • Series

    Trade Wars: Tariffs Threaten To Outweigh Tax Reform Gains

    Erica York

    In the next installment of this series examining the dimensions of the Trump administration's trade agenda, Erica York of the Tax Foundation discusses how the economic harm caused by tariffs could slow or offset the economic and employment benefits of tax reform.

  • Tax Savings Available With Pre-Immigration Planning

    Patrick McCormick

    A multitude of tax considerations are relevant for those considering immigration to the United States. Taking action prior to immigration is paramount in both optimizing planning opportunities and avoiding prospective tax headaches, says Patrick McCormick of Drucker & Scaccetti.

  • Tax Evasion Knows No Borders

    Kim Marie Boylan

    The former CEO of a U.K. bank recently pled guilty to charges under the Foreign Account Tax Compliance Act, following a U.S. Department of Justice sting operation spanning several countries. The conviction sends a clear message that U.S. authorities will prosecute not only U.S. account holders, but those who facilitate tax evasion, whatever their nationality, say attorneys at White & Case LLP.

  • 4 Key Problems With The Proposed EU Digital Tax

    Sigurd Næss-Schmidt

    As discussions continue regarding the proposed European Commission digital services tax, we suggest that European finance ministers examine four major issues with the proposal including its economic basis and its actual impact if it were to be implemented, say Sigurd Næss-Schmidt and Bruno Basalisco of Copenhagen Economics.

  • Some Indonesia Corps. Pay 0% Income Tax Under New Regs

    Ria Muhariastuti

    Indonesia recently issued new tax regulations aiming to improve the investment climate, increase state revenue, simplify administrative provisions and provide guidance for taxpayers. Ponti Partogi and Ria Muhariastuti of Hadiputranto Hadinoto & Partners discuss key highlights, including the opportunity for taxpayers to receive a 100 percent corporate income tax deduction.

  • 6 More Recommendations For Improving FATCA Compliance

    Rusudan Shervashidze

    This summer the U.S. Department of Treasury inspector general for tax administration issued a final audit report on Foreign Account Tax Compliance Act enforcement, concluding that after spending nearly $380 million, the IRS is still not prepared to enforce compliance. Rusudan Shervashidze and Nina Krauthamer of Ruchelman PLLC discuss the inspector general's recommendations and the IRS response.

  • 5.5 Ways To Remove GILTI From Your State Tax Base

    Zal Kumar

    In many states, the lack of specific guidance addressing the inclusion of global intangible low-taxed income, or GILTI, is causing concern that GILTI will be includible in the state tax base. Attorneys from Mayer Brown LLP highlight several possible avenues for removing GILTI from the state tax base.

  • The Curious Case Of The Accidental American Taxpayer

    Michael DeBlis III

    Accidental Americans — citizens of other countries born on U.S. soil but with no ties to the U.S. — may be surprised to learn they are subject to the same tax filing obligations, payments and penalties as self-identifying "Americans abroad," says Michael DeBlis of DeBlis Law.